Davidson Group Privacy Notice

At Davidson Holdings, we take individuals’ privacy seriously. We are committed to protecting your privacy.

This privacy notice (“Notice”) explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure. This Notice may change from time to time so please check this page occasionally to ensure that you are aware of any changes.

This Notice was last updated in June 2024.

Who we are

We are Davidson Holdings Limited (incorporated under English law with company number 04970157). The Davidson Holdings group also includes:

• Cistermiser Ltd: https://www.cistermiser.co.uk/
• Keraflo Ltd: https://www.keraflo.co.uk/
• Salamander Pumped Shower Systems Ltd: https://www.salamanderpumps.co.uk/
• Talon Manufacturing Ltd: https://www.talon.co.uk/

The data controller responsible for your personal data will be the company’s website you are accessing or the company with which you are contracting. For the purposes of this Notice ‘we’, ‘our’ and ‘us’ means the relevant data controller of your personal information.

What personal information do we collect about you and how?

The personal information we collect and the ways in which we collect it are as follows:

When you visit our website or install one of our apps

• If you submit an online request, we may ask you to provide your name, contact information and contact preferences.
• We may collect information about your computer or device and internet or other electronic network activity information. This includes:
  • Device identifiers, such as IP address, WIFI MAC address, and Bluetooth address;
  • Geolocation information such as your mobile device’s Global Positioning System (GPS) technology, other technology (such as wireless transmitters known as beacons) and information about your contacts, depending on your device settings;
  • Information about your online activity, including information collected through the use of standard internet technologies, such as cookies, pixels, web beacons, logs, and other internet technologies, and your offline activity; and
  • Through Google Analytics or similar software,information about the use of our website such as how often you visit our website, what pages you visit, and what other sites you used prior to visiting our website.
• If you make an account with us or join one of our loyalty programmes we shall also store information related to the account such as username, access levels, security details and your activities on the account and the details of your loyalty rewards.
• We may also collect certain information about you that is not personal information. This may include intellectual property or other company information you share with us, in accordance with any applicable agreements between you or, if applicable, your company: this might include, for example, trademarks, logos and other intellectual property which you own. We also might collect and/or generate anonymised and aggregated information from your use of our website. We use anonymised and aggregated information in various ways, including to measure your interest in and use of portions or features of our website. Anonymised or aggregated information is not personal information.

When you correspond with us

• We may record your calls with us for quality and training purposes and to enable us to deal effectively with queries and complaints. The personal information captured will include your phone number and any details raised during the conversation.
• When you send us an email, chat, SMS or otherwise correspond with us, we may make a record of our communication. Your personal information will include contact details, the contents of the communication, any insurance applications and any information relating to your insurance claims, information relating to legal claims made by you or against you or the claims process.
• When you engage with us on social media we may make a record of your interest. Your personal information may include contact details and the contents of the communication.
• We will also collect your personal information where you enter into a prize draw or competition. The personal information will include your name, contact details, any details related to the prize or competition and any associated interest in any of our products or services.

When you place an order on behalf of a company

• In connection with any order, contract or other arrangement entered into or negotiated with you (whether in your capacity as a supplier, customer, potential customer or otherwise), the personal information we collect will include your employer, your role, your work contact details, your work address and details of any correspondence you have with us in relation to the order. This may also include warranty information is applicable.
• When you make an order, we may also generate information about your order relating to the occurrence, investigation or prevention of fraud.
• If you book an appointment to attend an event with us such as a service engineer visit, training course or sales event. The information we would collect includes your contact details, the event you are interested in and any ancillary information related to the event such as accessibility requirements.

When you place an order as a sole trader or otherwise in a personal capacity

• In connection with any order, contract or other arrangement entered into or negotiated with you (whether in your capacity as a supplier, customer, user of one of our products or services, potential customer or otherwise), your personal contact details, your postal address, and payment details. This may also include warranty information is applicable.
• When you make an order, we may also generate information about your order relating to the occurrence, investigation or prevention of fraud.

When you apply for a job with us

• In connection with the interview and onboarding process for candidates and / or new joiners whether as officers (including directors), consultants or employees. The personal information we collect includes your contact details, CV, references and any other information needed to hold an interview with you.

How and why do we use your personal information?

The purposes for which we use your information and the legal basis under data protection laws on which we rely are explained below.

Where you have provided CONSENT

We may use and process your personal information where you have consented for us to do so:

• to conduct marketing activities where legitimate interests cannot be relied on including the use of cookies; and
• to use cookies which are not essential to the functioning of the website - when you first visit our website you will be asked if you would like to accept all cookies or customise your settings - if you select all cookies this will also enable us to perform activities based on your interactions with the website.

Where we are processing your personal information on the basis of your consent, you may withdraw that consent at any time. Please see ‘Withdrawing your consent’ in Section 9 below for further details.

Where there is a LEGITIMATE INTEREST of our business or the legitimate interests of others

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:

Where we have a legitimate interest to send you marketing communications:

• if you are a business customer we shall send you marketing information about any products we think you may be interested in; and
• if you are a sole trader or otherwise a customer in your personal capacity, we shall only send you marketing materials with your consent or where you have already made a purchase of a similar product or service either directly with us or indirectly through one of our customers and you have not opted-out of receiving such communication.

Where we have a legitimate interest to conduct an effective recruitment process:

• to review your CV, work experience and references;
• to arrange and conduct an interview including understanding any adjustments we may need to make to the interview process to make it suitable for you; and
• to make you an offer of employment with us.

Where we have a legitimate interest to optimise our websites and apps:

• generating statistics on our users, such as the popularity of certain of our services and about the “traffic” visiting our websites in order to improve our services to you;
• to analyse how you use our site to improve accessibility and navigation;
• to maintain your account;
• to personalise your experience and to develop the services we offer; and
• to ensure that content from our website is presented in the most effective manner for you and for your device.

Where we have a legitimate interest to provide you the best service:

• to offer you prizes, competition entry and loyalty schemes;
• to offer you after sales support;
• to manage your warranty and any associated claims; and
• for the management of queries and complaints.

Where we have a legitimate interest to comply with our legal obligations and establish and defend our legal rights:

• to monitor our correspondence in case of any dispute or complaint;
• to enforce or defend our legal rights or any claims;
• for prevention of fraud and other criminal activities; and
• to comply with a request from you in connection with the exercise of your rights.

Where we have a legitimate interest to operate the administrative and technical aspects of our business efficiently and effectively:

• to ensure payment verification, insurance, debt tracing and debt recovery;
• to notify you about changes in the terms of service;
• to keep our client records up to date;
• for maintaining records, publishing corporate information and public administration;
• for fraud prevention and detection purposes;
• as is necessary in conducting a corporate acquisition or disposal, or other transaction; and
• to share your information with third parties for the purposes set out in this Notice (unless consent is required).

Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations: (i) to assist any regulatory or public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data we hold about you, where legally necessary.

Where it is required to complete a CONTRACT

We may use and process your personal information in connection with a contract:

• for the supply of products or services when it is needed to carry out that contract or for you to enter into it; and
• for an employment contract where we need your personal information in order to offer you a job.

Usually, the provision of this data is necessary for us to provide our services to you. If you choose not to provide any of this data then it will impact our ability to provide you with the services you request or to offer you a job.

Who is your personal information shared with?

We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf.

Such third parties may include:

• cloud software system providers, including database, email and document management providers;
• advertising, PR, digital and creative agencies;
• website and app developers;
• IT providers that host our website, provide us with support services and/or store data on our behalf;
• Customer survey providers in order to receive feedback and improve our services;
• law enforcement bodies and/or other regulatory entities in order to comply with any legal obligation;
• potential or actual purchasers of the company in the event that we are sold (fully or partially), integrated with another business;
• legal, auditing, accounting and other professional advisors;
• third parties such as payment processors and in order to facilitate the provision of goods or services to you; and
• companies or sole traders, business partners, suppliers and sub-contractors who may install or service our products for you either directly on our behalf or because we introduce them to you and you choose to engage them (“Business Partners”).

When we share minimal information with Business Partners to complete our contract with you and to enable Business Partners to provide their services on your request. Business Partners are directly responsible to you for how they handle your personal information so any complaints or questions about a Business Partner’s use of your information should be addressed to the Business Partner.

When we use third party service providers processing data on our behalf, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions. Before we allow any transfer to occur we ensure the third-party has in place adequate technical and organisational measures to ensure your personal data is kept secure to a level appropriate to the risk.

To assist with the administration of the Davidson group, your personal data may also be shared between the companies listed at the top of this Notice.

Will my data be transferred outside the UK or EEA?

All information you provide to us is stored on our secure servers which are located within the United Kingdom (UK) or European Economic Area (EEA).

If at any time in the future, we transfer your personal information to, or store it in, countries located outside of the UK or EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law, such as:

• relying on declarations made by regulators or governments (e.g. adequacy decisions/regulations);
• where the third country that data is being sent to is not subject to such declaration, the standard contractual clauses approved by relevant regulators or governments, as applicable;
• ensuring that the recipients are subscribed to international frameworks; or
• such alternative measures as are valid and appropriate at the time.

How long we keep your personal information for?

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.

We may need your personal information to establish, bring or defend legal claims. For this purpose, we may retain your personal information after the date it is no longer needed by us, in accordance with our data retention policy, for any of the purposes listed under Section 3 above. The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see Section 9 below); or
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.

Security and links to other sites

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.

We have implemented appropriate physical, technical and organisational measures designed to secure your information against accidental loss and unauthorised access, use, alteration or disclosure. In addition, we limit access to personal information to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

Our website may contain links to other websites run by other organisations. This Notice does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the practices of other websites even if you access them using links that we provide.

Cookies

Our website uses cookies. Cookies are small text files that are stored on your computer’s hard drive by websites you visit to enable the website to ‘remember’ who you are. In general, cookies are only visible to the website that serves them, not to other websites. ‘Serves’ means places on your computer’s hard drive.

We use the cookies on this website to ‘remember’ information so that it can be passed from page to page and to collect website statistics. For example, when registering for our newsletters and email alerts, the information you put into the form on any page is stored on the webserver, and a cookie is used to point to that information. When you click ‘next’ to go to the next page of the form, our website reads the cookie which points back to the stored information so that it can be accessed by our website.

On accessing any of our websites, you were presented the opportunity to “accept”, “reject” or “customise” your cookie selection. If you would like further information on the types of cookies in use on the website including: names, purposes, any relevant third parties and the duration the cookie will remain on your device then you can select “customise” to be shown additional details on the cookies.

Your rights

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

• Accessing your personal information

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address in Section 11 below. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

• Correcting and updating your personal information

The accuracy of your information is important to us, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described in Section 11 below.

• Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out in Section 3, you may withdraw your consent at any time by contacting us using the details in Section 11 below. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

• Objecting to our use of your personal information

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as set out in Section 3, you may object to us using your personal information for these purposes by emailing or writing to us at the address in Section 11 below. Except where we have other purposes to process your information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.

• Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address in Section 11 below. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

• To restrict processing of your personal information

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

• Transferring your personal information in a structured data file

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out in Section 3, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine-readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

• Complaining to the UK data protection regulator

You have the right to complain to the Information Commissioners Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.

Changes to this Notice

We may review this Notice from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this Notice whenever you visit our website. If you do not agree with any aspect of the updated Notice, you must immediately notify us and cease using our services.

Contact us

Please direct any queries about this Notice or about the way we process your personal information using our contact details below.

Our email address for data protection queries is:

Group queries: webenquiries@davidsonholdings.co.uk

Salamander: marketing@salamanderpumps.co.uk

Talon: webenquiries@talon.co.uk

Cistermiser: info@cistermiser.co.uk

Keraflo: info@keraflo.co.uk